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Compliance Audit Terms

For Solicitors​

Audit Rights, Rectification, Suspension

and Regulatory Reporting Provisions

E-Solicitors Legal Services Marketplace

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Platform Audit and Enforcement Rights​

Audit | Rectification | Suspension | Regulatory Reporting

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Version 1.0 - January 2026

England and Wales

Important Notice to Solicitors​

  • BY REGISTERING ON THE PLATFORM, YOU ACKNOWLEDGE AND CONSENT TO THE PLATFORM'S RIGHT TO AUDIT YOUR COMPLIANCE WITH PLATFORM TERMS AND REGULATORY REQUIREMENTS.

Platform Audit Rights

The Platform has the right to audit your compliance with:

Platform Terms and Conditions

SRA Standards and Regulations

SRA Code of Conduct

SRA Accounts Rules

Law Society practice standards

Money Laundering Regulations 2017

LSAG Anti-Money Laundering Guidance 2025

FCA requirements (where applicable)

Due diligence obligations

Audit Process

🔍 AUDIT: The Platform may conduct routine, triggered, or random audits

🔍 AUDIT: You must cooperate fully with all audit requests

🔍 AUDIT: Failure to cooperate is a breach of Platform Terms

Right to Rectify

🔧 RECTIFICATION: For most compliance issues, you will be given an opportunity to rectify

🔧 RECTIFICATION: Rectification periods depend on severity of the issue

🔧 RECTIFICATION: Some serious matters may not be eligible for rectification

Suspension Rights

⏸ SUSPENSION: The Platform may suspend your access for compliance failures

⏸ SUSPENSION: Suspension may be immediate for serious matters

⏸ SUSPENSION: Suspension continues until issues are resolved

Regulatory Reporting

📢 REGULATORY REPORT: The Platform reserves the right to report serious matters to regulators

📢 REGULATORY REPORT: This includes reporting to SRA, Law Society, FCA, NCA, and other authorities

📢 REGULATORY REPORT: You consent to such reporting as a condition of Platform registration

Contents​

Part A: General Provisions​

  1. Definitions

  2. Purpose and Scope

  3. Your Acknowledgment and Consent

  4. Platform's Rights

Part B: Compliance Standards​

  1. Platform Terms Compliance

  2. SRA Compliance

  3. Law Society Compliance

  4. AML/KYC Compliance

  5. FCA Compliance

  6. Due Diligence Compliance

Part C: Audit Framework​

  1. Types of Audit

  2. Audit Triggers

  3. Audit Procedures

  4. Information Requests

  5. Cooperation Requirements

Part D: Audit Findings​

  1. Categories of Findings

  2. Notification of Findings

  3. Your Response Rights

Part E: Rectification​

  1. Right to Rectify

  2. Rectification Periods

  3. Rectification Requirements

  4. Verification of Rectification

  5. Matters Not Eligible for Rectification

Part F: Suspension​

  1. Grounds for Suspension

  2. Immediate Suspension

  3. Suspension Following Rectification Failure

  4. Effect of Suspension

  5. Lifting Suspension

Part G: Termination​

  1. Grounds for Termination

  2. Termination Procedure

  3. Effect of Termination

Part H: Regulatory Reporting​

  1. Right to Report

  2. Matters Subject to Report

  3. Reporting Procedure

  4. Your Consent to Reporting

Part I: Indemnity​

  1. General Indemnity

  2. Audit-Related Indemnity

  3. Regulatory Reporting Indemnity

Part J: Appeals and Disputes​

  1. Internal Review

  2. Dispute Resolution

Part K: General Provisions​

  1. Data Protection

  2. Confidentiality

  3. Governing Law

Schedules​

Schedule 1: Compliance Audit Areas

Schedule 2: Audit Cooperation Requirements

Schedule 3: Rectification Periods by Category

Schedule 4: Suspension and Termination Triggers

Schedule 5: Regulatory Reporting Triggers

Schedule 6: Audit Acknowledgment

Part A: General Provisions​

  1. Definitions

1.1 In this Agreement:

'AML' means anti-money laundering.

'Audit' means any review, inspection, assessment, or verification conducted by or on behalf of the Platform.

'Audit Finding' means any issue, concern, non-compliance, or breach identified during an Audit.

'Claim' means any claim, action, proceeding, demand, liability, loss, damage, cost, or expense.

'Compliance Standards' means all requirements with which you must comply under Platform Terms and applicable regulations.

'Critical Finding' means an Audit Finding of the most serious nature requiring immediate action.

'FCA' means the Financial Conduct Authority.

'Indemnified Parties' means the Platform, its parent companies, subsidiaries, affiliates, directors, officers, employees, and agents.

'Law Society' means The Law Society of England and Wales.

'Losses' means all losses, liabilities, damages, costs, expenses (including legal fees), fines, penalties, and other amounts.

'Major Finding' means a significant Audit Finding requiring prompt rectification.

'Minor Finding' means a less serious Audit Finding that should be addressed.

'MLR 2017' means the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended).

'NCA' means the National Crime Agency.

'Platform' means [Platform Name], operated by [Company Name].

'Platform Terms' means all terms, conditions, and agreements applicable to your Platform registration.

'Rectification' means correcting, remedying, or addressing an Audit Finding.

'Rectification Period' means the time allowed for Rectification.

'Regulator' means any regulatory body with jurisdiction over your activities including SRA, Law Society, FCA, NCA, HMRC, ICO, and others.

'SRA' means the Solicitors Regulation Authority.

'Suspension' means temporary restriction or removal of your Platform access.

'Termination' means permanent removal of your Platform registration.

'You/Your' means the solicitor or authorised body subject to these Terms.

  1. Purpose and Scope

2.1 The purpose of this Agreement is to:

(a) Establish the Platform's right to audit your compliance;

(b) Define the audit process and your cooperation obligations;

(c) Establish rectification rights and procedures;

(d) Define suspension and termination rights;

(e) Establish the Platform's right to report to Regulators;

(f) Protect the Platform, its users, and the public interest.

2.2 This Agreement applies to all solicitors and authorised bodies registered on the Platform.

  1. Your Acknowledgment and Consent

3.1 By registering on the Platform, you acknowledge and consent to:

(a) The Platform's right to audit your compliance;

(b) Providing information and documents as requested;

(c) The rectification process and timeframes;

(d) The Platform's right to suspend your access;

(e) The Platform's right to terminate your registration;

(f) The Platform's right to report to Regulators;

(g) The indemnity provisions in this Agreement.

  • REQUIRED: Your consent is a condition of Platform registration. If you do not consent, you cannot use the Platform.
  1. Platform's Rights

4.1 The Platform has the right to:

(a) Conduct audits of your compliance at any time;

(b) Request information and documents from you;

(c) Require you to rectify compliance failures;

(d) Suspend your Platform access;

(e) Terminate your Platform registration;

(f) Report matters to Regulators;

(g) Take any other action necessary to protect the Platform and its users.

4.2 These rights are exercised at the Platform's discretion, acting reasonably and in good faith.

Part B: Compliance Standards​

ℹ These are the compliance areas subject to Platform audit.

  1. Platform Terms Compliance

5.1 You must comply with all Platform Terms including:

(a) Solicitor Terms and Conditions;

(b) SRA Compliance Validation Terms;

(c) KYC/AML Compliance Terms;

(d) AI Use Disclosure Terms;

(e) Client Funds Management Terms;

(f) Indemnity and Liability Terms;

(g) All other applicable Platform Terms.

5.2 Audit areas include:

(a) Accuracy of registration information;

(b) Maintenance of required documentation;

(c) Compliance with operational requirements;

(d) Payment of Platform fees;

(e) Adherence to service standards.

  1. SRA Compliance

6.1 You must comply with all SRA requirements including:

SRA Requirement

Key Audit Areas

SRA Principles

Acting with integrity, honesty, independence

SRA Code of Conduct

All Code requirements

SRA Accounts Rules

Client money handling, reconciliations

SRA Transparency Rules

Pricing and service information

SRA Indemnity Rules

PII requirements

Practising Certificate

Valid and unrestricted

COLP/COFA

Compliance officers in place (if applicable)

Continuing Competence

CPD and competence maintenance

6.2 The Platform may audit:

(a) Your SRA registration status;

(b) Practising certificate conditions;

(c) Disciplinary history;

(d) Compliance officer appointments;

(e) Evidence of SRA compliance systems.

  1. Law Society Compliance

7.1 You must comply with Law Society requirements including:

(a) Practice standards and guidance;

(b) Accreditation requirements (CQS, Lexcel, etc.);

(c) Professional standards;

(d) Membership obligations (if applicable).

7.2 The Platform may audit:

(a) Accreditation status;

(b) Compliance with accreditation standards;

(c) Accuracy of accreditation claims.

  1. AML/KYC Compliance

8.1 You must comply with AML/KYC requirements including:

Requirement

Audit Areas

MLR 2017

Registration, policies, procedures, training

LSAG 2025

Guidance compliance, beneficial ownership (>25%)

Risk Assessment

Practice-wide and matter-specific

CDD Procedures

Client identification and verification

EDD Procedures

Enhanced checks where required

Source of Funds

Verification procedures

Ongoing Monitoring

Client relationship monitoring

Record Keeping

AML records maintained

SAR Procedures

Suspicious activity reporting

Training

Staff AML training

  1. FCA Compliance

9.1 If you conduct FCA-regulated activities, you must comply with:

(a) FCA Handbook requirements;

(b) Consumer Duty obligations;

(c) Client money and assets rules;

(d) Conduct of business requirements;

(e) Reporting and notification requirements.

9.2 The Platform may audit:

(a) FCA authorisation or exemption status;

(b) Compliance with applicable FCA rules;

(c) Consumer Duty implementation.

  1. Due Diligence Compliance

10.1 You must maintain proper due diligence including:

(a) Client identification and verification;

(b) Matter risk assessment;

(c) Conflict checking;

(d) Source of funds verification;

(e) Source of wealth verification (where applicable);

(f) Sanctions screening;

(g) PEP identification.

Part C: Audit Framework​

  1. Types of Audit

11.1 The Platform may conduct the following types of audit:

Audit Type

Description

Notice

Routine Audit

Regular scheduled review of compliance

Reasonable notice (typically 14 days)

Triggered Audit

Audit following complaint, concern, or event

May be shorter notice or none

Random Audit

Unannounced spot-check

No prior notice

Thematic Audit

Review of specific compliance area across multiple solicitors

Reasonable notice

Follow-up Audit

Verification of rectification

Reasonable notice

Urgent Audit

Immediate review due to serious concerns

No prior notice

  1. Audit Triggers

12.1 Audits may be triggered by:

(a) Scheduled routine review cycle;

(b) Client complaints about your services;

(c) Information suggesting compliance concerns;

(d) SRA or other regulatory action against you;

(e) Changes to your registration or status;

(f) Random selection for spot-check;

(g) Industry-wide concerns or thematic reviews;

(h) Your own notifications of issues;

(i) Media reports or public information;

(j) Any other reasonable cause for concern.

  1. Audit Procedures

13.1 Audits may be conducted by:

(a) Platform compliance team;

(b) External auditors or consultants;

(c) Specialist compliance reviewers;

(d) Any combination of the above.

13.2 Audit methods may include:

(a) Document review and verification;

(b) Information requests;

(c) Questionnaires and self-assessments;

(d) Interviews or meetings;

(e) Review of public records and registers;

(f) Third party verification;

(g) On-site or virtual inspections (with notice);

(h) Any other reasonable audit method.

  1. Information Requests

14.1 The Platform may request:

(a) Copies of policies and procedures;

(b) Evidence of compliance systems;

(c) Training records;

(d) Risk assessments;

(e) CDD documentation (redacted as appropriate);

(f) Reconciliation records;

(g) Insurance certificates;

(h) Regulatory correspondence;

(i) Accountant's reports;

(j) Any other relevant documentation.

14.2 Information must be provided:

(a) Within the timeframe specified (typically 7-14 days);

(b) In the format requested;

(c) Completely and accurately;

(d) With appropriate redaction of client confidential information.

  1. Cooperation Requirements

15.1 You must cooperate fully with audits by:

(a) Responding to requests within specified timeframes;

(b) Providing accurate and complete information;

(c) Making yourself available for interviews if required;

(d) Facilitating access to relevant systems or premises;

(e) Not obstructing or delaying the audit;

(f) Notifying the Platform of any difficulties in complying.

  • Failure to cooperate with an audit is a serious breach of Platform Terms and may result in immediate suspension.

Part D: Audit Findings​

  1. Categories of Findings

16.1 Audit Findings are categorised as follows:

Category

Description

Examples

Typical Response

Critical

Most serious - immediate risk

Client money misappropriation, fraud, loss of SRA authorisation

Immediate suspension, regulatory report

Major

Significant non-compliance

Missing AML policies, lapsed PII, SRA investigation

Rectification required, possible suspension

Minor

Less serious issues

Outdated documents, minor procedural gaps

Rectification required

Observation

Improvement recommendations

Best practice suggestions

No mandatory action

  1. Notification of Findings

17.1 Following an audit, the Platform will:

(a) Notify you of findings in writing;

(b) Specify the category of each finding;

(c) Explain the basis for each finding;

(d) Specify required actions (if any);

(e) Specify rectification periods (if applicable);

(f) Explain consequences of non-rectification.

17.2 Notification will typically be provided within:

(a) 24 hours for Critical Findings;

(b) 7 days for Major Findings;

(c) 14 days for Minor Findings and Observations.

  1. Your Response Rights

18.1 You have the right to:

(a) Receive clear explanation of findings;

(b) Provide additional information or explanation;

(c) Challenge findings you believe are incorrect;

(d) Request reconsideration before action is taken;

(e) Be given reasonable time to respond (except for Critical Findings).

18.2 Responses must be:

(a) In writing;

(b) Submitted within the specified timeframe;

(c) Supported by evidence where relevant.

Part E: Rectification​

🔧 RECTIFICATION: The Platform believes in supporting compliance and will generally give you an opportunity to rectify issues before taking more serious action.

  1. Right to Rectify

19.1 Subject to the exceptions below, you will be given an opportunity to rectify Audit Findings before suspension or termination.

19.2 The right to rectify demonstrates the Platform's commitment to:

(a) Fair treatment of solicitors;

(b) Supporting compliance improvement;

(c) Proportionate responses to issues;

(d) Constructive engagement.

  1. Rectification Periods

20.1 Rectification periods depend on the category and nature of the finding:

Finding Category

Standard Period

Extended Period (if justified)

Notes

Critical

Not applicable

Not applicable

Immediate action required

Major - Serious

7 days

14 days

E.g., lapsed insurance

Major - Standard

14 days

28 days

E.g., policy gaps

Minor - Urgent

14 days

28 days

E.g., outdated documents

Minor - Standard

28 days

42 days

E.g., procedural improvements

20.2 Extensions may be granted if:

(a) You demonstrate good faith efforts;

(b) Rectification genuinely requires more time;

(c) You request an extension before the deadline;

(d) The Platform agrees in writing.

  1. Rectification Requirements

21.1 Rectification must:

(a) Fully address the finding;

(b) Be completed within the rectification period;

(c) Be evidenced to the Platform's satisfaction;

(d) Include measures to prevent recurrence;

(e) Be genuine and not merely cosmetic.

21.2 You must provide:

(a) Written confirmation of rectification;

(b) Evidence of actions taken;

(c) Details of preventive measures;

(d) Explanation of root cause (for Major Findings);

(e) Any other information requested.

  1. Verification of Rectification

22.1 The Platform may verify rectification by:

(a) Reviewing evidence provided;

(b) Requesting additional information;

(c) Conducting a follow-up audit;

(d) Third party verification;

(e) Any other reasonable method.

22.2 Following verification:

(a) If satisfied - the matter is closed;

(b) If not satisfied - further action may be taken;

(c) If partially satisfied - additional rectification may be required.

  1. Matters Not Eligible for Rectification

23.1 The following matters are NOT eligible for rectification and may result in immediate suspension or termination:

(a) Fraud or dishonesty;

(b) Misappropriation of client money;

(c) Loss of SRA authorisation or practising certificate;

(d) Criminal conviction for relevant offences;

(e) SRA intervention;

(f) Serious misconduct affecting clients;

(g) Material misrepresentation to the Platform;

(h) Repeated failures after previous rectification;

(i) Failure to cooperate with audit;

(j) Any matter posing immediate risk to clients or the public.

  • These matters trigger immediate suspension and potential regulatory reporting without a rectification opportunity.

Part F: Suspension​

  1. Grounds for Suspension

24.1 The Platform may suspend your access for:

(a) Critical Audit Findings;

(b) Major Findings not rectified within the rectification period;

(c) Multiple Minor Findings indicating systemic issues;

(d) Failure to cooperate with audit;

(e) Information suggesting serious compliance concerns;

(f) SRA investigation or disciplinary proceedings;

(g) Loss or restriction of practising certificate;

(h) Lapsed professional indemnity insurance;

(i) Client complaints indicating serious issues;

(j) Any other matter that reasonably justifies suspension.

  1. Immediate Suspension

25.1 The Platform may suspend you immediately (without prior rectification opportunity) for:

Ground

Justification

Fraud or dishonesty

Immediate risk to clients

Client money misappropriation

Immediate risk to client funds

Loss of SRA authorisation

No longer authorised to practice

SRA intervention

Practice no longer viable

Criminal charges (relevant)

Serious integrity concerns

Material misrepresentation

Fundamental breach of trust

Serious harm to clients

Immediate protection required

Failure to cooperate with urgent audit

Cannot verify compliance

Lapsed PII (not immediately remedied)

Clients unprotected

⏸ SUSPENSION: Immediate suspension takes effect upon notice to you. No prior hearing is required.

  1. Suspension Following Rectification Failure

26.1 If you fail to rectify within the rectification period:

(a) The Platform will notify you of intended suspension;

(b) You may make representations within 48 hours;

(c) The Platform will consider representations;

(d) Suspension will take effect if not satisfied.

  1. Effect of Suspension

27.1 During suspension:

(a) You cannot accept new instructions through the Platform;

(b) Your profile will not be visible to clients;

(c) You must complete existing matters appropriately;

(d) You must continue to cooperate with the Platform;

(e) Platform fees remain payable;

(f) All other Platform Terms remain in force.

27.2 Suspension does NOT:

(a) Release you from indemnity obligations;

(b) Affect matters commenced before suspension;

(c) Prevent the Platform from taking further action;

(d) Prevent regulatory reporting.

  1. Lifting Suspension

28.1 Suspension may be lifted if:

(a) The issue giving rise to suspension is resolved;

(b) You demonstrate compliance to the Platform's satisfaction;

(c) Any required rectification is completed;

(d) The Platform is satisfied continuation is appropriate.

28.2 The Platform may impose conditions on reinstatement including:

(a) Enhanced monitoring;

(b) Regular compliance reporting;

(c) Restrictions on services offered;

(d) Any other reasonable conditions.

Part G: Termination​

  1. Grounds for Termination

29.1 The Platform may terminate your registration for:

(a) Matters listed in clause 23.1 (not eligible for rectification);

(b) Failure to resolve matters during suspension;

(c) Repeated suspensions;

(d) Pattern of non-compliance;

(e) Permanent loss of SRA authorisation;

(f) Striking off from the roll of solicitors;

(g) Conviction for serious criminal offence;

(h) Fundamental breach of Platform Terms;

(i) Any matter making continued registration inappropriate.

  1. Termination Procedure

30.1 Before termination (except for immediate termination cases):

(a) The Platform will notify you of intended termination;

(b) You may make written representations within 7 days;

(c) The Platform will consider representations;

(d) The Platform will notify you of its decision.

30.2 Immediate termination may occur without prior notice for:

(a) Striking off from the roll;

(b) SRA intervention;

(c) Fraud or dishonesty;

(d) Serious criminal conviction;

(e) Any matter posing immediate serious risk.

  1. Effect of Termination

31.1 Upon termination:

(a) Your Platform registration ends immediately;

(b) Your profile is removed;

(c) You cannot accept new instructions through the Platform;

(d) You must complete existing matters appropriately;

(e) Outstanding fees remain payable;

(f) Indemnity obligations survive;

(g) Confidentiality obligations survive;

(h) Cooperation obligations continue for past matters.

31.2 Termination does NOT prevent:

(a) Regulatory reporting;

(b) Enforcement of indemnity obligations;

(c) Legal proceedings against you;

(d) Sharing information with other platforms or regulators.

Part H: Regulatory Reporting​

📢 REGULATORY REPORT: The Platform reserves the right to report serious matters to regulators. This is in the public interest and protects clients.

  1. Right to Report

32.1 The Platform has the right to report matters to Regulators including:

(a) Solicitors Regulation Authority;

(b) The Law Society;

(c) Financial Conduct Authority;

(d) National Crime Agency;

(e) HMRC;

(f) Information Commissioner's Office;

(g) Action Fraud;

(h) Police and law enforcement;

(i) Any other relevant authority.

32.2 Reporting is at the Platform's discretion, exercised reasonably and in good faith.

  1. Matters Subject to Report

33.1 The Platform may report the following matters:

Matter

Likely Report To

Notes

Loss of SRA authorisation

SRA

For their records

Client money issues

SRA, NCA

If suspicious or serious

Suspected money laundering

NCA (SAR)

Required if suspicion

Fraud or dishonesty

SRA, Police

Serious conduct

FCA breaches

FCA

If FCA-regulated activities

Data protection breaches

ICO

Serious breaches

Sanctions violations

OFSI, NCA

If suspected

Material misrepresentation

SRA

Professional misconduct

Pattern of non-compliance

SRA

Systemic issues

Harm to clients

SRA, Police

If serious or criminal

  1. Reporting Procedure

34.1 Before reporting (except where prohibited or impractical):

(a) The Platform will generally notify you of intended report;

(b) You may make representations;

(c) The Platform will consider representations;

(d) The Platform will make final decision.

34.2 The Platform may report without prior notice if:

(a) Required by law (e.g., SAR);

(b) Notice would prejudice investigation;

(c) There is immediate risk of harm;

(d) Delay would be contrary to public interest;

(e) Tipping off rules apply.

  1. Your Consent to Reporting

35.1 By accepting these Terms, you:

(a) Consent to the Platform making reports to Regulators;

(b) Waive any claim against the Platform for making good faith reports;

(c) Acknowledge that reporting is in the public interest;

(d) Agree to indemnify the Platform for any claims arising from reporting.

35.2 Your consent is irrevocable and survives termination of your registration.

  • Reporting to regulators may have serious consequences for you including investigation, disciplinary proceedings, and loss of authorisation. Maintain compliance to avoid this.

Part I: Indemnity​

  1. General Indemnity

36.1 You agree to indemnify, defend, and hold harmless the Indemnified Parties from and against all Claims and Losses arising out of or in connection with:

(a) Your non-compliance with Compliance Standards;

(b) Audit Findings relating to your practice;

(c) Actions taken by the Platform in response to compliance issues;

(d) Regulatory action against you;

(e) Claims by clients affected by your non-compliance;

(f) Any third party claims relating to your compliance failures.

  1. Audit-Related Indemnity

37.1 You indemnify the Indemnified Parties against Losses arising from:

(a) Conducting audits of your compliance;

(b) Acting on Audit Findings;

(c) Suspending your access based on audit results;

(d) Terminating your registration based on audit results;

(e) Costs of audits where material non-compliance is found.

🛡 INDEMNITY: You bear the costs of your non-compliance, including the Platform's costs in identifying and addressing it.

  1. Regulatory Reporting Indemnity

38.1 You indemnify the Indemnified Parties against Losses arising from:

(a) Making reports to Regulators about you;

(b) Cooperating with regulatory investigations;

(c) Providing information to Regulators;

(d) Any claims you make against the Platform for reporting;

(e) Any defamation or similar claims relating to reporting.

38.2 This indemnity applies to all good faith reports, even if subsequently found to be unfounded.

38.3 Indemnities are:

(a) NOT capped;

(b) Primary obligations;

(c) Survive termination;

(d) Enforceable by any Indemnified Party.

Part J: Appeals and Disputes​

  1. Internal Review

39.1 You may request internal review of:

(a) Audit Findings you believe are incorrect;

(b) Suspension decisions;

(c) Termination decisions (before finalisation);

(d) Other material decisions affecting you.

39.2 Review requests must:

(a) Be in writing;

(b) Be submitted within 7 days of the decision;

(c) Set out grounds for review;

(d) Include supporting evidence.

39.3 The Platform will:

(a) Acknowledge the request;

(b) Conduct a fair review by an appropriate person;

(c) Provide a reasoned decision;

(d) Communicate the outcome within 14 days (or longer if complex).

39.4 Internal review does NOT:

(a) Automatically stay suspension;

(b) Prevent regulatory reporting;

(c) Extend rectification periods;

(d) Create any right of external appeal.

  1. Dispute Resolution

40.1 Disputes not resolved by internal review may be referred to:

(a) Mediation (voluntary);

(b) The courts of England and Wales.

40.2 Nothing in this Agreement prevents you from:

(a) Seeking legal advice;

(b) Raising concerns with your own regulator;

(c) Accessing court proceedings if appropriate.

Part K: General Provisions​

  1. Data Protection

41.1 Audit information:

(a) Will be processed in accordance with the Platform's Privacy Policy;

(b) Will be used for compliance and audit purposes;

(c) May be shared with Regulators as described;

(d) Will be retained as required for legal and regulatory purposes.

41.2 You must ensure that any information you provide:

(a) Does not breach client confidentiality inappropriately;

(b) Is redacted where necessary to protect client data;

(c) Complies with data protection requirements.

  1. Confidentiality

42.1 The Platform will:

(a) Treat audit information confidentially;

(b) Only disclose as necessary for audit purposes;

(c) Share with Regulators only where appropriate;

(d) Protect information from unauthorised access.

42.2 Confidentiality does NOT prevent:

(a) Reporting to Regulators;

(b) Disclosure required by law;

(c) Use in legal proceedings;

(d) Sharing with professional advisers.

  1. Governing Law

43.1 This Agreement is governed by English law.

43.2 The courts of England and Wales have exclusive jurisdiction.

43.3 Each Indemnified Party may enforce indemnities under Contracts (Rights of Third Parties) Act 1999.

Schedule 1: Compliance Audit Areas​

Areas Subject to Platform Audit

Area

Key Elements

Evidence Required

SRA Registration

Valid authorisation, practising certificate, no restrictions

SRA record check, certificate copy

PII

Valid policy, adequate cover, qualifying insurer

Certificate of insurance

SRA Code Compliance

Principles, Code of Conduct

Policies, evidence of systems

SRA Accounts Rules

Client money handling (if applicable)

Reconciliations, accountant's report

COLP/COFA

Compliance officers in place (if applicable)

SRA record, appointment evidence

AML Policy

Practice-wide policy in place

Policy document, dated

AML Risk Assessment

Practice-wide risk assessment

Risk assessment document

CDD Procedures

Client identification and verification

Procedure documents

Staff Training

AML and compliance training

Training records

Conflicts

Conflict checking procedures

Conflict policy, evidence of checks

Complaints

Complaints procedure in place

Complaints policy

Data Protection

GDPR compliance

Privacy notices, policies

FCA (if applicable)

Authorisation, Consumer Duty

FCA register, policies

Accreditations

Valid accreditations as claimed

Certificates, evidence

SCHEDULE 2: AUDIT COOPERATION REQUIREMENTS

Your Cooperation Obligations

Requirement

Timeframe

Notes

Respond to initial audit notification

Acknowledge within 2 business days

Confirm receipt

Provide basic documents (policies, certificates)

Within 7 days of request

Standard request

Provide detailed documents

Within 14 days of request

Complex or voluminous

Complete questionnaires

Within 14 days of receipt

Self-assessment forms

Attend interview/meeting

Within 14 days of request

Reasonable scheduling

Respond to queries on documents

Within 7 days

Clarification requests

Provide rectification evidence

Within rectification period

After findings issued

Confirm completion of actions

Within 48 hours of completion

Written confirmation

Consequences of Non-Cooperation

Failure

Consequence

Failure to acknowledge audit notification

Reminder, then escalation

Late provision of documents (first occasion)

Warning, extended deadline

Late provision of documents (repeated)

Adverse inference, possible suspension

Refusal to provide documents

Treated as Critical Finding, suspension

Failure to attend meeting without good reason

Rescheduled once, then adverse inference

Providing false or misleading information

Immediate suspension, potential termination

Obstructing or delaying audit

Suspension, regulatory report consideration

SCHEDULE 3: RECTIFICATION PERIODS BY CATEGORY

Category

Finding Type

Standard Period

Maximum Extension

Critical

Fraud, dishonesty, misappropriation

None - immediate action

None

Critical

Loss of SRA authorisation

None - immediate action

None

Critical

Criminal proceedings (relevant)

None - immediate action

None

Major - Serious

Lapsed PII

7 days

14 days

Major - Serious

Missing AML policy

14 days

28 days

Major - Serious

No risk assessment

14 days

28 days

Major - Standard

Outdated AML policy

28 days

42 days

Major - Standard

Training gaps

28 days

42 days

Minor - Urgent

Expired certificates not renewed

14 days

28 days

Minor - Urgent

Minor policy gaps

14 days

28 days

Minor - Standard

Documentation improvements

28 days

42 days

Minor - Standard

Procedural enhancements

28 days

42 days

Observation

Best practice recommendations

No mandatory period

N/A

SCHEDULE 4: SUSPENSION AND TERMINATION TRIGGERS

Immediate Suspension Triggers

Trigger

Regulatory Report?

Termination Likely?

Fraud or dishonesty

Yes

Yes

Client money misappropriation

Yes

Yes

Loss of SRA authorisation

N/A (SRA aware)

Yes

SRA intervention

N/A (SRA aware)

Yes

Criminal charges (relevant offences)

Possible

Depends on outcome

Material misrepresentation to Platform

Possible

Likely

Serious harm to clients

Yes

Likely

Lapsed PII (not immediately remedied)

Possible

If not resolved

Refusal to cooperate with urgent audit

Possible

If not resolved

Suspension Following Rectification Failure

Finding

Rectification Failure

Next Step

Major - Serious

Not rectified within period

Suspension, then termination if not resolved

Major - Standard

Not rectified within extended period

Suspension, review

Multiple Minor

Pattern of non-compliance

Suspension, systemic review

Repeated findings

Same issue recurring

Suspension, possible termination

SCHEDULE 5: REGULATORY REPORTING TRIGGERS

Matters Likely to be Reported

Matter

Report To

Timing

Notice to You?

Client money misappropriation

SRA, possibly NCA

Immediate

After report if tipping off applies

Suspected money laundering

NCA (SAR)

Immediate

No (tipping off prohibited)

Fraud by solicitor

SRA, Police

Prompt

Generally yes unless prejudicial

Loss of SRA authorisation (discovered)

SRA (notification)

Prompt

Yes

Serious AML failures

SRA

After investigation

Yes, with opportunity to comment

FCA breaches (regulated activities)

FCA

Prompt

Yes

Serious data protection breach

ICO

As required by law

Yes

Pattern of client complaints

SRA

After review

Yes

Material misrepresentation

SRA

After investigation

Yes

Sanctions concerns

OFSI, NCA

Prompt

Depends on circumstances

Factors Affecting Reporting Decision

Factor

Weighs Towards Report

Weighs Against Report

Seriousness

Serious or repeated issue

Minor, isolated issue

Client harm

Actual or potential harm to clients

No client impact

Intent

Deliberate or reckless conduct

Genuine error or oversight

Cooperation

Non-cooperation, obstruction

Full cooperation

Rectification

Refused or failed to rectify

Promptly rectified

Pattern

Systemic or repeated issues

One-off occurrence

Public interest

Public protection requires report

No wider public interest

Legal requirement

Reporting is mandatory

Discretionary matter

SCHEDULE 6: AUDIT ACKNOWLEDGMENT

Acknowledgment of Audit and Enforcement Terms

I acknowledge and confirm that:

Acknowledgment

Confirmed

I consent to the Platform auditing my compliance

☐

I will cooperate fully with all audit requests

☐

I will provide information and documents as requested

☐

I understand findings will be categorised by severity

☐

I understand I will generally be given an opportunity to rectify

☐

I understand some matters are not eligible for rectification

☐

I understand I may be suspended for compliance failures

☐

I understand I may be terminated for serious or repeated failures

☐

I consent to the Platform reporting to regulators where appropriate

☐

I waive claims against the Platform for good faith reports

☐

I understand the indemnity provisions

☐

I agree to indemnify the Platform for audit and reporting costs

☐

I understand internal review is available but limited

☐

I agree to be bound by these Terms

☐

Signed: _______________________________________________

Name: _______________________________________________

SRA ID: _______________________________________________

Firm (if applicable): _______________________________________________

Date: _______________________________________________

Document Information​

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Regulatory Framework

SRA Standards and Regulations 2019 (as amended 2025)

SRA Code of Conduct for Solicitors

SRA Code of Conduct for Firms

SRA Accounts Rules 2019

SRA Indemnity Insurance Rules 2023

Money Laundering Regulations 2017 (as amended)

Legal Sector Affinity Group Guidance 2025

Proceeds of Crime Act 2002

FCA Handbook and Consumer Duty 2023

Data Protection Act 2018 / UK GDPR

Contracts (Rights of Third Parties) Act 1999

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Related Documents

Platform Terms - Solicitor Terms and Conditions V1.0

Platform Terms - Solicitor Indemnity and Liability V1.0

Platform Terms - SRA Compliance Validation V1.0

Platform Terms - KYC/AML Compliance V1.0

Platform Terms - Client Funds Management V1.0

Platform Terms - AI Disclosure V1.0

Privacy Policy V1.0

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Document Version: 1.0

Effective Date: January 2026

Last Updated: January 2026

Next Review: July 2026

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  • BY REGISTERING ON THE PLATFORM, YOU CONSENT TO AUDIT. The Platform will audit your compliance. You must cooperate. Compliance failures may result in rectification requirements, suspension, or termination. The Platform reserves the right to report serious matters to regulators including SRA, FCA, and NCA.